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TITLE | MAIN ISSUES |
AUGUSTUSA NDUKAUBA V. CHIEF SILAS M. KOLOMO | JURISDICTION:- Jurisdiction of court – Failure to serve court process – Effect on proceedings of court. |
AWOYEGBE AND ANOTHER V. OGBEIDE | JURISDICTION:- Courts – Competence of a trial court to grant relief not sought. |
AWUSE V. ODILI | JURISDICTION:- Court of Appeal – Jurisdiction of to entertain appeal arising from election petition – Source of-Finality of decision thereof – Extent of-Exception thereto. |
AYISATU ASABI EWUOSO V. RAUFU ADEOYE FAGBEMI | FEDERAL HIGH COURT – Jurisdiction – Jurisdiction over passing-Off actions – Whether includes all cases of trademarks infringement. JURISDICTION- Lack of jurisdiction on the part of trial and appellate Court- Effect thereof on judgment and orders made. JURISDICTION- Proper court to hear cases of passing-off when trade mark is not registered. |
AYUA V. ADASU | JURISDICTION ‑ Election Tribunal ‑ Jurisdiction of‑ Whether competent to hear petition founded on allegation of crime ‑ Section 28 of Act No. 271989 and section 84 of Decree 50, 1991 section 6(2)(3) and (5)1979 Constitution ‑ Effect. |
AZUOGALONUA V. OBIOZO | PRACTICE AND PROCEDURE – JURISDICTION- How to prove jurisdiction of inferior courts. |
BABA V. BABA | PRACTICE AND PROCEDURE – JURISDICTION:- Whether the Sharia Court of Appeal has jurisdiction in matters of succession |
BABA V. HABIB NIGERIA BANK LTD | PRACTICE AND PROCEDURE – JURISDICTION – Jurisdiction of court – determination of PRACTICE AND PROCEDURE – JURISDICTION – Jurisdiction of court – lack of – whether to dismiss or strike out action. |
BADA V. PEREIRA | |
BAKAM V. ABUBAKAR | JURISDICTION:- High Court -Jurisdiction to_ entertain intra-party dispute on nomination for political office – Whether extant JURISDICTION:- Issue of jurisdiction – When and how to raise JURISDICTION:- Issue of- When and haw to raise |
BALOGUN V. ODE | JURISDICTION – COURT:- Jurisdiction of court – Issue of – How determined -Processes court will consider. JURISDICTION – COURT:- Jurisdiction of court – Statute ousting same – How construed. |
BANK OF IRELAND V. U.B.N. LTD | JURISDICTION:- Issue of jurisdiction – When can be raised – How dealt with. |
BANK OF THE NORTH LTD. V. PATRICK MICHAEL AND ORS. | JURISDICTION:– Competence of a court – need for trial Judge to pronounce on same when raised at the earliest opportunity. |
BATURE MANYA V. STATE | JURISDICTION – RIGHT OF PARTIES:- Where a party either due to some carelessness or oversight overlooked a legal point bordering on the competence of a court at the earliest moment or opportunity – Whether he should not be stopped or barred from raising that point at a later date after he might have discovered the mistake – Whether jurisdiction being a fundamental gateway to an assumption of power can be raised at any time as the practice is not immutable – Whether the issue of service is jurisdictional and constitutional and is not capable of being waived |
BATURE V. STATE | JURISDICTION:- Competence of court – Determining factors. JURISDICTION:- Issue of competence of court – Whether a mere technicality. |
BAUCHI STATE AGRICULTURAL DEVELOPMENT PROGRAMME V. ALHAJI ABUBAKAR ABDULLAHI | JURISDICTION:- Whether a party can use any statutory provision or any Common Law principle to impose jurisdiction on court where same is lacking |
BELLO AKANBI AND OTHERS V. MAMUDU ALAO AND ANOTHER | JURISDICTION – CONSTITUTION BASIS – Matters not considered by High Court. – Rules of Courts – Functions of – Vis-a-vis Constitution. |
BELLO MUSA MAGAJI V. ALHAJI ISHOLA ARE OGELE | JURISDICTION:- Ingredients of jurisdiction – Duty of a party who challenges the jurisdiction of a court – Whether appellant should raise the issue with the leave of court – Whether parties to any proceedings can bestow jurisdiction on a court of law where none exists or expand or shrink a court’s jurisdiction |
BEN OBI NWABUEZE V. JUSTICE OBI OKOYE | PRACTICE AND PROCEDURE – JURISDICTION – Civil jurisdiction of court – principles governing exercise of same. PRACTICE AND PROCEDURE – JURISDICTION – Exercise of jurisdiction by court – conditions precedent to exercise of same. PRACTICE AND PROCEDURE – JURISDICTION – Unlimited jurisdiction of a State High Court under section 236 of 1979 Constitution – whether limited territorially under section 6(2) of 1979 Constitution. |
BESSOY LIMITED V. HONEY LEGON (NIG) LIMITED & Anor | JURISDICTION – CAUSE OF ACTION JURISDICTION OR ADJUDICATORY JURISDICTION: Whether a defendant is entitled to raise issues pertaining to jurisdiction at any stage in the proceedings |
BILLIRI V. BILLIRI | JURISDICTION:‑ Court ‑ Competence of ‑ How determined. JURISDICTION:‑ Court ‑ Defect in competence ‑ Consequence on proceedings. JURISDICTION:‑ High Court ‑ Bauchi State High Court ‑ Appellate jurisdiction ‑ When court duly constituted ‑Northern States High Court Law, Cap. 59, Section 40(1) considered. |
BONIFACE ISICHEI V. INDEPENDENT NATIONAL ELECTORAL COMMISSION (INEC) | COURT – JURISDICITION OF COURT: Effect of a court not having jurisdiction to entertain a matter |
BOYE INDUSTRIES LIMITED & ANOR. V. ADISA SOWEMIMO | JURISDICTION:- Determining factor of an appellate court’s jurisdiction over settled issues not properly brought as well as those not brought before it |
BRAWAL SHIPPING (NIG) LTD. V. EXTRACTION & COMMODITY SERVICE LTD | JURISDICTION:– Primacy and fundamental nature of – where court lacks same – effect of. JURISDICTION:– State High Court – unlimited jurisdiction of – whether had concurrent jurisdiction with Federal High Court under the Constitution of the Federal Republic of Nigeria 1979, sections 236(1) & 230 (1) |
BRIGGS V. BOB-MANUEL | JURISDICTION- State High Courts- Jurisdiction of State High Courts under section 236 of the 1979 Constitution. |
BUHARI V. OBASANJO | JURISDICTION:- Court of Appeal – Jurisdiction to act as Presidential Election Petition Court – Exclusive nature of – Source of. JURISDICTION:- Supreme Court – Jurisdiction of with respect to Presidential election petitions – Where derived from. |
C.G.G V. OGU | JURISDICTION:- Meaning and implications for judicial proceedings – High Court of a State – Whether has jurisdiction to entertain matters pertaining to mines, minerals, oil fields, oil mining, geological survey, natural gas – Section 251(1), Constitution of the Federal Republic of Nigeria, 1999 considered – Federal High Court – Jurisdiction to entertain causes and matters pertaining to mines, minerals, oil fields, oil mining, geological surveys, natural gas etc – Scope of powers – Whether concurrent with that of High Court of a State |
CAPITAL BANCORP LIMITED V. SHELTER SAVINGS AND LOANS LIMITED AND ANOTHER | JURISDICTION – Jurisdiction of court – What determines. JURISDICTION – High Court of a State – Jurisdiction of- Rules governing exercise of – Source of – Section 239, 1979 Constitution. |
CARIBBEAN TRADING & FIDELITY V. NIGERIAN NATIONAL PETROLEUM CORPORATION | JURISDICTION – SERVICE OUT OF JURISDICTION:- rule that leave of court should be sought before service of originating summons out of jurisdiction can be served |
CENTRAL BANK OF NIGERIA V. IFEANYICHUKWU OKONKWO | JURISDICTION:- Whether defect is fatal- how issue must be placed before the court – Guidelines for distinguishing between jurisdictional incompetence which is evident on the face of the proceedings and one which is dependent on the ascertainment of facts |
CHIEF AKIN OMOBORIOWO & ORS V. CHIEF MICHAEL ADEKUNLE AJASIN | JURISDICTION:- Ondo State High Court: Whether Ondo State High Court is competent to hear in election petition matters in Ondo State and can a single judge sit alone to hear the petition? |
CHIEF BERTHRAND E. NNONYE V. D. N. ANYICHIE & ORS | JURISDICTION:- Situations where objection to jurisdiction can be raised. |
CHIEF EVANS IHESI V. BARRISTER KENNETH ARINZE & ANOR. | JURISDICTION:- Purport of jurisdiction of a court |
CHIEF GREAT O. OGBORU & ANOR V. DR. E. E. UDUAGHAN & ORS. | JURISDICTION:- duty of court when jurisdiction is challenged- effect of a limitation law |
CHIEF J. D. UKPONG & ORS V. THE TRAD. RULERS COUNCIL | JURISDICTION:- Whether Jurisdiction must be vested in a Court of law before the rights of the parties can be determined |
CHIEF JACOB CLEOPAS BIARIKO V. CHIEF A.M. EDEH AND ORS | JURISDICTION:- Supreme Court – Jurisdiction of over appeal from court of trial – Whether extant – Section 213 of 1979 Constitution (section 233 of 1999 Constitution). |
CHIEF JOHN EZE V. OKECHUKWU | JURISDICTION:– High Court of Anambra State – uJurisdiction of same over a matter pertaining to the custom and tradition regarding chieftaincy |
CHIEF L.K. AJIBARE & ANOR V. JAMES AKOMOLAFE & ANOR | JURISDICTION:- Whether it is proper for plaintiff who has invoked the jurisdiction of a Court to attack the jrisdiction of the Court by setting up a plea of res judicata in his statement of claim. |
CHIEF O. A. AGURA & ANOR V. MR. B. A. I. OROBIYI & ANOR | JURISDICTION:- which party may raise an issue of competence or jurisdiction of the court |
CHIEF SIR VICTOR UMEH V. ICHIE OKULI JUDE EJIKE | JURISDICTION – ISSUE OF JURISDICTION:- Nature of – Whether the issue of jurisdiction is very fundamental and goes to the competence of the Court – Whether once the issue of jurisdiction is raised by the parties or by the court suo motu, that issue must be the first duty of the court to be determined, as a matter of priority |
CHIEF SUNDAY ORIORIO & ORS V. CHIEF JOSEPH OSAIN & ORS | JURISDICTION:- when issue must be resolved |
CHRISTOPHER OKEKE V. SECURITIES AND EXCHANGE COMMMISSION & ORS | JURISDICTION:- Fundamental nature of – Need for it to be accorded the highest degree of consideration and priority over and above any other issue – Where a court embarks upon a decision in any given matter without the requisite jurisdiction – Whether decision is null and void, and liable to be set aside – Whether the issue of jurisdiction can be raised at any stage of the trial, and at any point in time, either at the trial or on appeal in the court of appeal, or Supreme Court – Whether can be raised suo motu by court |
CHRISTOPHER ONJEWU V. KOGI STATE MINISTRY OF COMMERCE & INDUSTRY & ORS. | JURISDICTION: Whether where a court had no jurisdiction to make an order that it made it had jurisdiction to rescind it |
COMPAGNIE GENERALE DE GEOPHYSIQUE (NIGLT) CGG NIG LTD V. MOSES AMINU | JURISDICTION:- Competency of court – conditions precedent – Originating processes and jurisdiction – Need for parties to be properly before the Court for jurisdiction to vest over a matter – Failure to serve defendants with originating processes – Effect on competency of suit – Duty of court to first determine that it has jurisdiction before proceeding to rule whether that jurisdiction is excluded by statute or not – Whether jurisdiction can be raised at any stage of the proceedings |
CONGRESS FOR PROGRESSIVE CHANGE & ANOR V. HON. EMMANUEL DAVID OMBUGADU & ANOR | JURISDICTION:- Definition – Whether so fundamental or basic while also being radical that it cannot be ignored or run away from since any decision reached in its absence is a nullity – Whether possible to raise question of jurisdiction at any point in the litigation whether at the very beginning, in the middle of the trial and even at the Supreme Court for the very first time |
D. OGUNREMI & ORS V. S. OGUNREMI & ORS | JURISDICTION:- Jurisdiction – Whether rule of court confers jurisdiction. |
DALFAM NIGERIA LIMITED V. OKAKU INTERNATIONAL LIMITED | JURISDICTION:– Issues relating to jurisdiction – Need for court to first consider and determine same – Whether a party who initiated an action is entitled to question the jurisdiction of the court. JURISDICTION:– Jurisdiction of court – Proceedings conducted by trial Judge outside its jurisdiction – Nullity of. |
DALHATU V. TURAKI | JURISDICTION – Jurisdiction of the High Court of the Federal Capital Territory – Extent of. JURISDICTION:– Whether a claim to party nomination is justiciable. JURISDICTION:– Whether High Court has jurisdiction over disputes arising from the nomination of party candidates for election. |
DANGIDA V. MOBIL PRODUCING NIG. UNLTD. | JURISDICTION:– Jurisdiction of court – How determined – Need to examine the statement of claim. JURISDICTION – Jurisdiction of the Federal High Court – Purport of the decision in NDIC V. FMB (1997) 2 NWLR (Pt. 490) 735 explained. JURISDICTION:– Section 230(1)(c) of the 1979 Constitution as amended by Decree 107 of 1993 – Claim by custom officer for injuries sustained in the course of his duties – Whether the Federal High Court has exclusive jurisdiction over such claim. |
DANGOTE GEN. TEXTILE PRODUCTS LTD & ORS V. HASCON ASSOCIATES NIG. LTD & ANOR | JURISDICTION – A STATE HIGH COURT: The jurisdiction of a State High Court under the provisions of Section 270(1) and Section 272(2) of the 1999 Constitution |
DINGSE V. REGISTERED TRUSTEES OF CHURCH OF CHRIST IN THE SUDAN | JURISDICTION:– Primacy of jurisdictional issues – court lacking the jurisdiction to hear and determine the matter before it – effect of. JURISDICTION:– Proposed amendment of the constitution of a church – whether within the jurisdictional competence of the Federal High Court or State High Court. JURISDICTION:– Question of ordination of church priest – whether within the jurisdictional competence of the Federal High Court or State High Court. |
DR. ADEWUNMI ADEYEMI-BERO V. LSDPC & ANOR | JURISDICTION:- whether court can adjudicate over ancillary claims if it has no jurisdiction to entertain the main claim |
DR. AKPO MUDIAGA-ODJE V. YOUNES POWER SYSTEM NIGERIA LTD. | JURISDICTION:- How determined – General practice to closely examine the Writ of Summons, the Statement of Claim and motion papers if any including affidavit evidence and annextures thereto – How treated |
DR. DARU & ORS V. BARRISTER IBRAHIM AMINU UMAR | JURISDICTION:- Nature and essence of – How determined – Duty of court to promptly investigate and determine challenge to jurisdiction when raised by party or suo motu – Need for court to confine itself to the examination of the writ of summons and the statement of claim in order to determine whether or not it has jurisdiction to adjudicate on the claimant’s or the plaintiff s suit – Justification |
DR. IME SAMPSON UMANAH V. OBONG (ARC.) VICTOR ATTAH & ORS | JURISDICTION: Whether a judgment obtained by fraud can be used as basis for conferring jurisdiction in court where it has none |
DR. TAIWO OLORUNTOBA-OJU & ORS. V. PROFESSOR SHUAIB O. ABDUL-RAHEEM & ORS. | JURISDICTION: How determined |
DR. TOSIN AJAYI V. PRINCE (MRS.) OLAJUMOKE ADEBIYI & ORS | JURISDICTION:- When an objection to jurisdiction can be taken- relevant things to be considered by the court in determining the issue of jurisdiction – Duty of curt when issue of jurisdiction is raised – distinction between objection to Jurisdiction and demurrer – What Locus Standi is – Guiding principles to determine whether a person has locus standi or not- Whether locus standi is interwoven with jurisdiction- when issue of locus standi can be raised- Whether Locus standi to institute proceedings in a court is dependent on the success or merits of a case – Responsibility of a party who challenges the competence of a court on the basis of certain facts |
DR. UMAR ARDO & ANOR V. ADMIRAL MURTALA NYAKO & ORS | JURISDICTION:– nature of- court process to be used in determining jurisdiction |
EKPUK V. OKON | JURISDICTION:– Issue of jurisdiction – whether can be raised at anytime – whether required to be properly raised before court can entertain it. JURISDICTION:– Types of jurisdiction known to law – Type of jurisdiction that can be waived – Type that cannot be waived. |
ELIAS NNADI AND 16 OTHERS V. THE QUEEN | JURISDICTION:- Section 70 of Criminal Procedure Ordinance – Whether judge can assume jurisdiction. |
EL-RUFAI V. THE HOUSE OF REPRESENTATIVES, NATIONAL ASSEMBLY OF THE FEDERAL REPUBLIC OF NIGERIA | JURISDICTION:– Court – jurisdiction – what determines same. JURISDICTION:– Courts jurisdiction – whether lower court had jurisdiction to entertain suit. |
EMELOGU V. THE STATE | JURISDICTION:- State High Court – Jurisdiction to try robbery offences under the Firearms (Special provisions) Act, 1970 – Criminal Procedure (Miscellaneous Provisions) Law No. 19 of 1974, East Central State – Effect of. |
EMEZI V. OSUAGWU | JURISDICTION:- Locus standi – Absence of locus standi – Effect on jurisdiction of court. |
EMMANUEL EGWUMI V. THE STATE | COURT – JURISDICTION:- When a court is said to be competent – Three relevant considerations – Proper constitution as regards members and qualifications of the members of the bench – Subject matter jurisdiction – Case origination by due process of law, and upon fulfillment of any condition precedent to the exercise of jurisdiction – Duty of court thereto |
EMUZE V. VICE CHANCELLOR UNIVERSITY OF BENIN | JURISDICTION:- Statute Ousting jurisdiction of Court-How construed. JURISDICTION:- Jurisdiction of Court-Importance of. |
ENAGI V. INUWA | JURISDICTION:‑ Election Petition Tribunal ‑ Scope of jurisdiction of ‑ Whether can determine a question solely in the province of National Electoral Commission. |
ENGR. AYO IJAGBEMI & ANOR. V. MR. JOEL OLUWOLE IGE & ANOR. | JURISDICTION:- When a court is competent to determine or hear an action brought before it |
ENWEREMADU V. OHAJURUKA | JURISDICTION:- Enabling statute – role of same in defining the nature and scope of a courts jurisdiction. JURISDICTION:- Federal High Court – whether has jurisdiction under section 15 of the Federal High Court Act on matters within the exclusive preserve of a State House of Assembly. |
ERHUNMWUNSE V. EHANIRE | JURISDICTION:- High Court-Land subject of Statutory Right of Occupancy -Exclusive jurisdiction of High Court. JURISDICTION:- Jurisdiction of Court- Customary Court jurisdiction-How determined JURISDICTION – Jurisdiction of Court-Determination of. |
EROKORO V. GOVERNMENT OF CROSS RIVER STATE | JURISDICTION:- Court of Appeal – Jurisdiction of – Where derived. JURISDICTION – Jurisdiction of court – Source of. |
ESEWE V. EGBE | |
ESIN V. ABASI AND OTHERS | JURISDICTION:- The pre-1955 Supreme Court – Original jurisdiction under section 11 of cap. 211; summary jurisdiction under s. 10 of cap. 185, trial under order for re-trial made under s. 28 (1) (b) of cap. 142. |
ESSANG V. AUREOL PLASTICS LTD | JURISDICTION:– Civil jurisdiction of the Akwa Ibom State High Court under section 22 of the High Court Laws of Cross River State Cap. 51 vol. III applicable in Akwa Ibom State – Conditions precedent to the exercise of same. |
ETUWEWE V. ETUWEWE AND ETUWEWE | JURISDICTION:- Inheritance of property – Whether High Court was not competent to hear the suit that pertained to a matter which was subject to the jurisdiction of a customary court – Whether subject matter falls within the proviso of section 9(1) of the High Court Law of Western Nigeria |
ETUWEWE V. ETUWEWE | JURISDICTION- High Court -When it has original jurisdiction in respect of inheritance and disposition of property. JURISDICTION – CUSTOMARY LAW:- Native court – Inheritance and disposition of property on death – Seized with original jurisdiction. |
EZE V. FEDERAL REPUBLIC OF NIGERIA | JURISDICTION:- Determination of jurisdiction – Alleging of falsification of document – Jurisdiction of Federal High Court – Objection to jurisdiction to be raised at any stage – Whether jurisdiction still vests where charge as laid alleges breach of law cognisable by the coon, but statement of offence and evidence disclose offences not cognisable by the coon. |
EZEGBU V. FIRST AFRICAN TRUST BANK LIMITED (CA | JURISDICTION:‑ Exercise of jurisdiction ‑ Condition precedent thereto ‑ of non‑fulfilment of |
EZEKIEL ADEDAYO V. ALHAJI YAKUBU BABALOLA AND ORS | JURISDICTION:- State High Court – Jurisdiction of – Scope of |
EZENWO NYESOM WIKE & ANOR V. SAMUEL ROGERS ICHENWO & ANOR | JURISDICTION:- What determines jurisdiction of Court JURISDICTION:- Whether the issue of jurisdiction can be raised at any stage of the proceedings and what the Court should do once it is raised |
EZENWO NYESOM WIKE V. SAMUEL ROGERS ICHEONWO | JURISDICTION – TRIBUNAL’S JURISDICTION:- Effect of a tribunal’s determination given without jurisdiction |
EZEONU V. AGHEZE | JURISDICTION:- Court of Appeal – Prevention of discontinuance of cases – Whether Court of Appeal has jurisdiction. JURISDICTION:- Inherent jurisdiction – Meaning of. JURISDICTION:- Inherent jurisdiction – Nature and scope of – When not to be invoked. |
F.B.I.R. V. REZCALLAH AND SONS LTD. | JURISDICTION:- High Court – Whether it has power to consider validity of assessments in action for recovery of tax |
FAJINMI V. SPEAKER, WESTERN HOUSE OF ASS. | JURISDICTION:- Legislation providing that legislative Assembly should make rules in respect of parliamentary elections – Assembly failing to – Action brought in normal form -Attitude of Court. |
FAJUKE V. OGEDENGBE(2) | JURISDICTION:- Federal Supreme Court – Power to entertain application for stay of execution when no appeal has been entered. |
FALADE V. COMMISSIONER FOR EDUCATION | JURISDICTION:- Ouster of court’s jurisdiction clauses – Decree No. 17 of 1984 – Effect of ouster clause therein. |
FASAKIN FOODS LTD. V. SHOSANYA | JURISDICTION:- Jurisdiction of Court – Proper order to make when a Court finds that it lacks jurisdiction to entertain a suit. |
FAWEHINMI V. AKILU (CA1) | JURISDICTION:- Inherent jurisdiction of court – What it means – Whether can extend statutory jurisdiction of court. JURISDICTION:- Of courts – Where derived. JURISDICTION:- Supreme Court- Original jurisdiction to grant declaratory relief – Whether and when extant. ‘ |
FEDERAL GOVERNMENT OF NIGERIA V. ADAMS OSHIOMHOLE | JURISDICTION:- Jurisdiction of court – Nature and importance of-Where court lacks jurisdiction to entertain matter before it – Effect JURISDICTION:- Jurisdiction of court – Where court lacks jurisdiction over main claim – Effect on its jurisdiction to entertain ancillary claim. JURISDICTION:- Jurisdiction of court – Where Federal Government or any of its agencies a party to a suit – Proper court with jurisdiction to determine same. |
FEDERAL MORTGAGE BANK OF NIGERIA V. ENGR. JOHN OSA UWADIALE | JURISDICTION:- Duty of Court where it lacks jurisdiction – Effect of Court proceedings, judgment or orders in the absence of jurisdiction |
FEDERAL MORTGAGE BANK OF NIGERIA V. NIGERIAN DEPOSIT INSURANCE CORPORATION | JURISDICTION: Extent of jurisdiction of the Federal High Court in respect of banker – Customer disputes/transactions as provided in the proviso to section 230(l )(d) of the 1979 Constitution as amended by the Constitution (Suspension and Modification) Decree No. 107 of 1993; Goods and chattels attached by a bailiff before the appointment provisional liquidator; constitutionality of the registry judgment. |
FEDERAL POLYTECHNIC BAUCHI & ANOR V. ABDULFATTAH ABOABA & ANOR | JURISDICTION – APPEAL:- Whether an issue of jurisdiction cannot be raised for the first time in an appellate court unless and until leave has been sought and obtained by an applicant – Whether the issue of jurisdiction can be raised by a party anyhow, anywhere and anyhow, for as long as the other party is not caught by surprise but given an opportunity to react to same |
JUDGMENTS BY AREAS OF PRACTICE
JUDGMENTS BY PRACTICE/PROCEDURE ISSUES